South African Pharmacists File Six CPD Entries, Not Hours

Most CPD regimes count hours. The South African Pharmacy Council counts submissions. A pharmacist files six CPD entries a year, each supported by a portfolio of evidence, and the number of hours behind those entries is not what is assessed. In December 2024 the Council also quietly took two months off the deadline.

Six entries, annually

The Council's own compliance notice puts the requirement as "submitting at least six (6) CPD entries for the year 2024", with the window that "ends on Friday, 28 February 2025". An earlier notice states the same shape for a different year — "six (6) CPD entries on an annual basis", for "the current year of compliance (i.e., 2022)", "by the submission deadline of 31 December 2022".

So the architecture is: six entries, counted per calendar year, submitted into the Council's database after the year ends.

One housekeeping note before anything else, because it wastes people's time: the Council's website is pharmcouncil.co.za. The abbreviation SAPC leads a lot of searchers to the wrong domain.

The grace period was shortened on 13 December 2024

This is the change most likely to catch a pharmacist out, and it is a reduction rather than an extension.

Board Notice 706 of 2024, published in Government Gazette 51765 on 13 December 2024 and made under "Regulation 5(1) of the Regulations relating to continuing professional development", amends the CPD guidance document. It is final — the Council "hereby publishes for implementation the amendments".

What changed, in the notice's own words: the provision that read "A grace period ending on 30 April of the subsequent year of submission will be allowed;" "shall hereby be replaced with: 'A grace period ending on the last day of February (i.e. 28 or 29 February) of the subsequent year of submission will be allowed;'"

Two months gone. A pharmacist working to an April deadline from memory, or from older guidance, is two months late.

The Council's own brochure still prints the old date

Worth knowing if you go looking for the rule yourself. The SAPC CPD Brochure says entries "must be submitted on the database by 1 February of the following year" with "A three-month grace period for submission will be allowed" — which lands in early May, the pre-amendment position.

Board Notice 706 of 2024 is later and is the gazetted instrument, so it governs. The brochure is stale. This is the second South African regulator we have found whose published guidance has fallen behind its own gazetted rules, and it is a good argument for always checking the gazette rather than the explainer.

Entries and portfolios, not hours

The brochure sets out what sits behind each entry: "All registered persons are required to keep an electronic portfolio of evidence against all CPD entries", and the CPD process is described as a cycle of Reflection, Planning, Implementation and Evaluation.

We should be careful about how we characterise this. SAPC does not use the phrase "outcomes-based" anywhere we could find, and we are not going to put that word in its mouth. What is defensible is narrower and more useful: it counts entries rather than hours, each entry requires documented evidence, and the structure asks the pharmacist to reflect and plan rather than only to attend.

The practical consequence for anyone buying training is that attendance alone does not produce a compliant entry. The entry has to be written up against the cycle, with evidence retained electronically. A course is an input to an entry, not an entry.

For the record: CPD was "introduced in 2010", and "The Regulations relating to continuing professional development were published in the Government Gazette" on 17 May 2019.

What happens if you do not file

The consequence is stated plainly and it is not a fine: "you will be designated as a non-practising pharmacist or disciplinary action will be instituted against you". The earlier notice uses the same framing — the risk of "being designated nonpractising or being referred for disciplinary action".

Being designated non-practising is a change to your professional status rather than a penalty payment, which makes it considerably more serious than it sounds.

How this sits against the rest of South Africa

Within one country, the models diverge sharply by profession. Pharmacists file six portfolio entries a year. Attorneys owe nothing at all — the Legal Practice Council has held the power to impose compulsory development since 2014 and has never used it, which we set out in South African attorneys have no mandatory CPD. Chartered accountants have no hours or points target either, under an output-based model covered in SAICA CPD requirements.

So a South African pharmacist has the most structured ongoing obligation of the three, and it is the only one of the three expressed as a count of anything.

Across the continent the divergence is wider still — Kenyan accountants need 40 hours a year against Ghana's 35, with different verifiable splits and home-body quotas, which we compare in why there is no such thing as African CPD.

A checklist

1. Plan for six entries across the calendar year, not a number of hours.
2. Keep an electronic portfolio of evidence against each entry as you go — reconstructing it in February is the hard way.
3. Write each entry against the reflection, planning, implementation and evaluation cycle.
4. Submit by the end of February following the compliance year. Not April.
5. Check the gazette rather than the brochure if the two disagree.

This article describes the requirement as published by the South African Pharmacy Council and gazetted in Board Notice 706 of 2024. It is not professional advice; verify current deadlines with the Council before relying on them.